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payment, at his last known address, as provided for in
IRC � 6303. Review of transcripts have confirmed the
tax was assessed 7/8/2002, and notice and demand was
mailed to the taxpayer at his last known address, and
there is still a balance due.
IRC section 6320(a) provides that the IRS will notify a
taxpayer of the filing of a NFTL and of the right to a
hearing before the IRS Office of Appeals with respect
to the filing of NFTL. Such notification was mailed to
you 3/24/2003.
* * * * * * *
This Appeals Officer has had no prior involvement with
respect to these liabilities.
Relevant Issues Presented by the Taxpayer
The request for a Collection Process Due Hearing filed
by the taxpayer stated “mathmaticaly incorrect.” The
taxpayer did not file a return, and does not believe
that she has “gross income” or owes the tax. A proper
assessment was made on 07/08/2002 after mailing the
Statutory Notice of Deficiency to the taxpayer’s last
know address on 2/11/2002. She has been given the
opportunity to dispute the assessment before it was
made. No alternative to the filing of the NFTL was
suggested.
Balancing the Efficient Tax Collection with Concern
Regarding Intrusiveness
Appeals has verified, or received verification, that
applicable laws and administrative procedures have been
met; has considered the issues raised, and has balanced
the proposed collection action with the legitimate
concerns that such action be no more intrusive than
necessary as required by IRC 6330(c)(3). The case will
be returned to compliance for any action they deem
appropriate.
The filing of the lien, in this case, properly balances
the need for efficient collection action with concerns
over the level of intrusiveness necessary to accomplish
collection of the liability. It is Appeals determina-
tion that Compliance properly followed all procedures
and properly filed the lien.
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